Regarding our recent coverage of the FAA’s letter to lighting vendors FAA Lighting Letter Leaves Contractors In the Dark, Mike Forhan, Director of Engineering at Hughey & Phillips, LLC sent us a reply. Mike told us he is a long-time private pilot and sees this as a safety issue “in which he has a personal stake.” -JF
Dear Mr. Fryer,
I read with interest your article, “FAA Lighting Letter Leaves Contractors In the Dark,” published in the August 17, 2018 issue of Inside Towers. As the FAA noted in your article, the FAA’s position regarding the use of non-OEM parts has not changed. Their long-standing policy is stated in FAA Advisory Circular 150/5345-53D, “Airport Lighting Equipment Certification Program (ALECP),” which says in part: “The certification is not valid for a product modified with non-OEM replacement parts or non-production components.”
The concerns from industry execs noted in your article confirms our experience that this fact is not common knowledge. When we have previously mentioned it to customers, their belief is that this policy applies only to new lighting equipment. One customer even commented, “it’s like my car. Ford uses original equipment parts to build their cars, but I don’t have to go back to Ford for replacement parts.” The reality—hopefully made clear with the FAA’s letter—is that the ALECP does not work that way.
The purpose of the ALECP is to establish a certification process to ensure that the equipment meets the FAA’s published standards for airport lighting equipment. The FAA also maintains a list of certified equipment that tower contractors and maintainers can refer to. This list is important, because manufacturers of airport lighting equipment sometimes misleadingly state that their equipment “complies with” or “conforms to” or “meets” FAA certification requirements. Such wording is intended to suggest that the equipment is FAA certified, when it is not. The list of certified equipment may be found at this FAA link.
Having said all that, the prevailing industry question has been: what difference does it really make if maintainers of obstruction lighting equipment install non-OEM parts? The suppliers of the non-OEM parts claim that their parts are designed to meet or exceed the published specifications of the original equipment manufacturer. But do they? Given that no non-OEM replacement parts have been independently tested in OEM systems, there’s no way to know. Just because the non-OEM part seems to work is no indication that it works as well as an original equipment part and interacts properly with the other components of the lighting equipment under demanding environmental conditions, or lasts as long as original equipment parts. There is also no assurance that two or more non-OEM parts installed in certified lighting equipment will work properly with each other and with original equipment components.
It should also be noted that the quality of FAA-certified equipment is monitored by the FAA’s certifier under the ALECP. No such quality monitoring exists for non-OEM parts. Buying cheaper non-OEM parts that don’t work properly or last as long as original equipment parts is just false economy.
At the end of the day, the primary goal is for airport lighting equipment to work properly and reliably to protect the flying public. Another important goal is minimize maintenance costs for tower owners and operators. The best way to accomplish both of these goals is to use only original equipment parts to maintain certified airport lighting equipment. We recommend that tower lighting contractors and maintenance personnel address this with their customers. As part of this discussion, we suggest mandating replacement of non-OEM parts with original equipment parts. Although this will initially require additional work and expense, we believe it’s a worthwhile investment in safety and reliability.
Sincerely,
Michael A. Forhan
Director of Engineering
HUGHEY & PHILLIPS, LLC
Inside Towers welcomes letters to the editor (send to [email protected]).
August 29, 2018
